Key Updates in the CMS Fiscal Year (FY) 2025 State Performance Standards System (SPSS)

Key updates in the CMS Fiscal Year (FY) 2025 State Performance Standards System (SPSS) guidance for State Survey Agencies, with a focus on changes from the 2024 to 2025 guidance.

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Retired Measures: Data Submission and Survey Upload Timeliness
In the FY 2024 SPSS, CMS required State Survey Agencies to submit data and upload recertification surveys promptly to ensure smooth information flow and transparency. However, with the implementation of the iQIES (Internet Quality Improvement and Evaluation System), these processes are now automated. iQIES’s integration across survey systems allows for seamless uploads, tracking, and data access, reducing manual intervention and making these specific metrics unnecessary. This advancement reflects CMS's shift towards utilizing technology to reduce administrative workload while still maintaining high standards for data integrity and availability.

New Measure for the Survey and Intake Quality Domain: Deficiency Citation and Tasks Investigated
For FY 2025, CMS introduced a new quality measure, “Nursing Home Recertification Survey Deficiency Citation and Tasks Investigated,” in the Survey and Intake Quality domain. This measure combines multiple sub-measures to ensure comprehensive assessment during nursing home recertification surveys. CMS will evaluate the number of deficiencies per 1,000 beds, the percentage of deficiency-free surveys, and the types of deficiencies identified at various severity levels (e.g., G, H, I, J, K, and L scope and severity). Additionally, the measure includes a requirement to complete specific tasks—both mandatory and triggered—to guarantee all critical aspects are investigated. This consolidated approach provides a holistic view of survey quality and focuses on critical components that impact resident safety and care standards.

Updated Comparative Survey Measure: Deficiency Identification Consistency
CMS reintroduced an updated “Assessment of Deficiency Identification using Federal Comparative Surveys” for FY 2025. This measure gauges how closely State Survey Agency findings align with those of federal surveys conducted by CMS. Comparative surveys are designed to evaluate consistency, accuracy, and adherence to federal standards across agencies. The updated measure allows CMS to assess whether state agencies are identifying similar issues at comparable scope and severity levels. By improving alignment, CMS aims to create a standardized approach across states, reducing variability in survey outcomes and ensuring that all facilities meet the same expectations for quality and compliance.

Enhanced Scoring System with the New “Requires Research” Category
In addition to the existing “Met,” “Partially Met,” and “Not Met” scoring categories, CMS has introduced a “Requires Research” category in FY 2025, specifically for the new Nursing Home Recertification Survey Deficiency Citation and Tasks Investigated measure. When agencies score below the threshold for this composite measure, they will receive the “Requires Research” classification instead of a standard score. This category enables CMS and the state agency to collaboratively investigate the root causes of low performance without immediately triggering corrective actions. This change reflects a supportive and diagnostic approach, focusing on understanding and addressing underlying issues before applying penalties.

Increased Emphasis on Immediate Jeopardy (IJ) Cases
CMS is intensifying its focus on Immediate Jeopardy (IJ) cases, which involve situations posing serious threats to resident health and safety. The FY 2025 SPSS guidance mandates that State Survey Agencies reduce the backlog of overdue IJ cases by at least 35% by the end of the fiscal year. This increase from previous standards underscores the importance of prompt investigation and resolution of critical incidents. CMS will closely track progress across provider types, including nursing homes and acute care facilities, to ensure agencies are managing high-risk incidents effectively and within established timelines.

Off-Hour Survey Requirements to Capture Varied Operational Conditions
To improve the accuracy of survey findings, CMS’s FY 2025 guidance mandates that at least 10% of nursing home recertification surveys be conducted during off-hours, including weekends, early mornings, evenings, and federal holidays. Conducting surveys during these times provides insights into facility operations under non-standard conditions, such as potential staff shortages. Additionally, 50% of these off-hour surveys should occur on weekends, and at least 80% of weekend surveys should focus on facilities with identified staffing issues, particularly those flagged for low weekend staffing. This approach helps CMS and state agencies monitor for quality consistency throughout various operational hours.

Enhanced Timeliness and Accountability Standards for State Survey Agencies
To strengthen accountability, CMS’s FY 2025 guidance introduces stricter deadlines and more precise corrective actions for State Survey Agencies. Agencies failing to meet performance targets consistently over two years (e.g., scoring “Not Met” or “Partially Met”) are required to develop Corrective Action Plans. These plans should address deficiencies and provide a structured timeline for improvement. CMS has introduced additional timelines for key milestones, ensuring that agencies take timely steps toward compliance. This updated accountability framework aims to create a culture of continuous improvement among State Survey Agencies, ultimately raising the standard of care and operational quality within facilities under their purview.

These changes in the FY 2025 SPSS guidance reflect CMS’s dedication to improving survey efficiency, quality, and responsiveness. The updated measures and scoring approach encourage State Survey Agencies to prioritize high-impact issues, enhance survey quality, and maintain consistency with federal standards across various operational contexts. These revisions aim to drive systemic improvements across Medicare and Medicaid-certified facilities, helping to safeguard the health and safety of residents nationwide.